Taxpayers argue that deferred compensation expense earned prior to the enactment of 250(b) Foreign Derived Intangible Income should not...

Draft 2021 Schedules K2 and K3 Released (IR-2021-98; April 30, 2021) The IRS has released draft Schedules K-2 and K-3 for the Forms 1065,...

The Sourcing Rules §861-865 The sourcing rules have an important purpose for US persons and non-US persons. Since a US person is taxed in...